Shine a light – the impact of EU regulations

31 July 2014



New EU regulations and a voluntary traffic light system are changing the way food packaging looks in the UK. Matthew Burgess speaks to Jill Marshall from London-based brand agency Bloom to learn how they are making an impact.


In December 2014, EU regulations on food packaging will come into force. The labelling rules will change the way nutrition and allergen information can be displayed to consumers. Included in the sweeping changes are clear requirements of food businesses as to what information they must give consumers and how to present it, as well as helping consumers understand what they can expect to be provided with when they decide to buy food.

The changes were passed into law in 2011, but they do not come into force until this year to allow designers and manufacturers to prepare for the changes and use existing stock.

The first sections of the new regulations were implemented on 1 January 2014 and involve provisions on the designation of minced meat. The last changes are set to come into force in 2016 - however, the majority will apply from 13 December 2014.

This is also supplemented by the UK Government pushing for companies to join up to its latest public health drive to include a traffic light system on the front of products.

Ring the changes

EU Regulation 1169/2011 has combined all existing food packaging regulations into one single piece of legislation. One of the biggest changes is the need for all allergen information to be highlighted on ingredient lists. This will mean the end to products brazenly displaying 'contains nuts' across the front of the packaging. Instead, all allergens will have to be highlighted, for example in bold, alongside the list of all ingredients. This is also going to be included on non-pre-packed foods for the first time.

A minimum font size for the mandatory information on most food labels will be implemented to aid clarity. The minimum size has been set at 1.2mm but can be reduced to 0.9mm if the largest packaging or container surface is 80cm2 or less. This may pose problems for those manufacturers whose products come in small packaging but use a large amount of ingredients.

Meat and fish products that look like a cut, joint or slice and contain more than 5% of added water will have to show this in the name of the food. The country-of-origin requirements have been tightened and extended to include fresh and frozen meat.

Other changes that will apply include displaying the type of vegetable oil used in food, and drinks with high caffeine content will have to be labelled as not recommended for children or pregnant women, with the caffeine content quoted.

After more than a year of difficult negotiations between the UK's Department of Health, NGOs, food manufacturers and other interested parties, a voluntary traffic light system was agreed upon. According to officials, 60% of products that are being sold in the UK are set to be included by the manufacturers that have signed up.

Among them are food giants Mars, Nestlé and PepsiCo, as well as all of the major supermarkets, who agreed to put the traffic light system on their own-brand products. The voluntary system combines traffic light colour-coding and nutritional information to display how much fat, saturated fat, salt, sugar and calories are in products.

Research by the Food Standards Agency has shown consumers prefer traffic light labelling, as it allows them to see the information at a glance. The combination of these regulations has led to wholesale changes in how food packaging is set to develop in the coming years, but what has this meant for designers and how will it impact upon consumers?

A lack of colour

Bloom is a brand-creation, development and delivery agency, based in South London, that works with a variety of food manufacturers and brands including Walkers, Rowntrees and Snack a Jacks.

Some of Bloom's clients have signed up to the voluntary traffic light system, others have not, but managing director Jill Marshall says one of the most important things is being able to provide transparency for consumers.

"If it's voluntary rather than 'you have got to sign up to it' - and then even using it on some products and not others within a company - you end up essentially without a level playing field, and I think that makes it quite difficult for consumers to work out what is going on," says Marshall.

"Anybody would be mad to say that transparency of information isn't important to consumers; I think food manufacturers have a responsibility to be transparent and honest about what is in their products."

Marshall adds that, while health is a massive factor in the food choices consumers make, it isn't the only factor in why people are picking certain products.

"Consumers still want taste," she says. "They're not prepared to trade taste for the sake of health benefits. Price is obviously a factor also; clearly there's been a lot of tightening of belts, and that still continues to be the case for a lot of people."

Size does matter

With mandatory font sizes and extra information needing to be included on the packaging of almost all items under the new EU regulations, this has forced designers to reconsider much of the pre-existing packaging.

"There's no rocket science to the design process, but what it does mean is that it's affecting how you place the information on a pack and the pack architecture," says Marshall.

"How much space can you give things? If you're going to have to make some things bigger, then you're going to have to make other things smaller, or they're going to have to be removed. So that does have to be taken into consideration."

The enforced changes may also lead to some compromise of packaging design, as there needs to be an evaluation of the desires of the manufacturer while also being able to comply with the regulations.

"Some packs are bigger than others," says Marshall. "It's fine if you're on a big cereal box, but, if you're on a quite-small packet of biscuits or a 330ml soft-drink bottle, you've got quite a lot of information to get on there, and you still need and want the branding to do its job in terms of communicating what the brand proposition is. It's a balancing act".

It will remain to be seen how much of an impact the changing regulations will have on consumers' purchasing habits and the performance of brands that have to make large changes to their packaging.

Marshall warns, however, that it is possible to over-regulate packaging laws and that future decision-makers have to take into account a brand's needs, as well as what the consumer is getting from the product.

"If food ever went the route of cigarette packaging, with half or a third of the pack taken up by warning labels - which, to be honest I think people kind of ignore anyway - it becomes wallpaper," she says.

"I think that doesn't necessarily allow the brand to communicate whatever messages it needs to communicate, especially in terms of quality and appetite appeal when you're talking about food.

"People buy a packet of biscuits because they want a nice packet of biscuits; if it has a third of the pack taken up by warnings, I think it can be quite off-putting."

Jill Marshall is managing director of London-based brand-development agency Bloom, having joined the firm from Design Bridge in 2005. She has 25 years’ experience in branding and design, with a particular interest in packaging and the fast-moving consumer goods sector.


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